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It is daunting.  As we see it, it will force us to either leave the
state to continue to do business or close most of our locations. 
The overall cost of putting a $20K filter on a $15-20K truck and
absorbing $600K in expenses is overwhelming and un-manageable.   
 
That is nearly 25% of our GROSS revenue's in any given year. In
this very difficult year of 2008, even more.  In California's
current economy with a 30% loss in revenue for us in 2008,
shouldering the cost of equipment replacement, the higher cost of
securing loans for replacement, higher interest rates and the
increasing difficulty of selling old equipment in the shadow of
these impending rulings, we are faced with a mountain to overcome.
 
Forced with that much of an impact, we would have no choice but to
close locations, lay off people and severely impact the revenues of
the business.  That means more unemployment, less revenue, less
taxes for California.  It will be a story repeated often in the
coming years with these regs as they read now.
 
We are a small company with a fleet of 30 trucks in the 89-2000
fleet age range.  Our trucks all average about 7500 miles per year
and drive just short distances to and from our training yards. 
Most of our time is spent in the yards backing up.  Our trucks do
not haul loads, go to ports or traverse the highways more than a
few miles per day.  Our trucks, by design, are "tortured" by new
drivers that don't know HOW to drive a big-rig.  It's why they go
to school.  In the process, these trucks go through high
maintenance costs anyway, with frequent clutches and wear and tear.
 We are fully state approved and participate in CHP BIT inspections
and Smoke tests.  We are fully compliant with both.
 
As such, we get as many miles out of our trucks as we possibly
can, due to ongoing maintenance costs and necessary cost vs return
formulas.  The need to have a brand new or near new fleet for our
application simply isn't feasible.   In fact, to do so would
require such a sizable increase in tuition costs to offset that
equipment purchase that most students couldn't afford to go to
school. As it is, students are having difficulty securing loans in
this constricted economy.  Either way, we lose as a small business
in California.
  
The other commercial driving schools in the state, which provide
drivers for all of the people that were in that auditorium today
are in similar situations.  It is a critical asset to the
California Transportation industry and economy witch will be
further exacerbated by a growing shortage of drivers here.
 
Your suggestions today that we simply all go out and buy newer
$50-60K+ trucks to replace our fleet is absolutely not feasible in
any business model I can generate. 
 
It appears that regardless of what we oppose, a regulation is
coming.  We have no problem with cleaner air, but the impact on
small business in California is going to be devasting.  With fuel
prices and the economy in the state it is now, many many small
California companies simply will not be able to absorb that cost. 
I point out that while some latitude for "small fleets" of 3 or
less has been allowed, fleets of our size, which is not uncommon in
California, are going to be severely impacted.
 
The 3 compliance options that have been introduced certainly do
give a bit of headroom, however no model portrayed by CARB allows
us latitude on the PM filters by the end of 2010.  That cost alone
shuts the doors of this 33 year old California based company.  
 
I'd ask that some further consideration for our particular "model"
be given, perhaps as either a new classification or under the
proposed exclusion for emergency vehicles, military tactical
vehicles or personal use motorhomes; all of which put more miles on
California's highways annually than any of our training trucks do.